The network of income tax treaties in Cyprus includes two new agreements. The income tax treaty between Cyprus and Spain has an entry into force date of 1 January 2015. The income tax treaty between Cyprus and the UAE was effective 1 January 2014.
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KPMG publications

Holding companies

2014

The Cyprus holding company regime is intended to provide tax advantages for those incorporating a Cyprus holding company.
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The European Commission released a report about tax trends in the European Union, revealing that in 2012, the overall tax-to-GDP ratio in the 28 EU Member States was 39.4 percent of GDP in 2012—up from 38.8 percent of GDP in 2011. Read more

Excise tax

March-December 2013

The European Commission issued a report reflecting efforts over a 10-month period (March-December 2013) to counter smuggling and fraud with respect to goods subject to excise tax in the European Union.
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VAT

16 June 2014

The European Commission announced that a VAT Expert Group has adopted an opinion on a “definitive VAT regime” for the VAT treatment of business-to-business supplies of goods.
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State aid

11 June 2014

The European Commission announced that it has opened three investigations to examine whether tax rulings (“comfort letters”) issued by the tax authorities in Ireland, the Netherlands, and Luxembourg—with regard to the corporate income tax to be paid by certain multinational corporations—comply with the EU rules on state aid.
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VAT

1 January 2015

The European Commission issued a reminder that the VAT rules for telecommunications, broadcasting, and electronic services in the EU will change effective 1 January 2015.
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Transfer pricing

4 June 2014

The European Commission adopted a “communication” that includes guidelines on three aspects of the treatment of transfer pricing transactions.
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Customs

2 June 2014

The European Commission announced the release of forms relating to customs enforcement of intellectual property rights.
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Proposed legislation

Parent-Subsidiary Directive

20 June 2014

The EU's Council of Economic and Finance (ECOFIN) Ministers reached an agreement on a revised version of the European Commission’s proposed amendments to the EU Parent-Subsidiary Directive. The revised text contains measures to combat the use of hybrid loans.
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There are new transfer pricing reporting requirements for certain entities in France, and a public consultation concerning the information return required to be filed, in order to report transfer pricing information, has just been announced by the French tax authorities.
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KPMG in Ireland has prepared a summary of some of the most frequently asked questions that relate to the general principles of transfer pricing and the new transfer pricing rules (in the Finance Act 2010) in Ireland. Read more

BEPS

May 2014

Ireland’s Department of Finance in late May 2014 launched a public consultation on BEPS in an Irish context and what this could possibly mean for the future of Ireland’s tax regime. Read more

The Moroccan government has committed to a national “green” agenda, which includes reducing its reliance on expensive fossil fuel imports (the country lacks fossil fuel reserves of its own) and increasing its production and use of renewable energy sources—including solar power and concentrated solar power in particular.
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Recent guidance provides that the Dutch tax and customs administration will exchange, with the tax authorities of other countries, information about Dutch resident companies whose main activities involve the intra-group receipt and payment of foreign interest, royalties, and rental or lease payments.
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Pension law

2015

The Upper House of the Dutch Parliament in late May 2014 passed a bill that would amend the pension law in the Netherlands.
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Dividend taxation

June 2014

The European Commission has requested that the Netherlands to end what is perceived to be the discriminatory taxation of dividends received with respect to shares held by insurance companies established in other EU Member States or in a European Economic Area country (Norway, Lichtenstein, and Iceland).
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Administrative and case law

VAT

12 June 2014

The Court of Justice of the European Union (CJEU) on 12 June 2014 issued a judgment concluding that discount cards sold to consumers, in order to provide for price reductions, did not fall within the scope of “securities” or “other negotiable instruments” for the purposes of the exemption from VAT.
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Tax consolidation

SCA Group Holding, C-39/13, C-40/13, and C-41/13

The CJEU issued a judgment in a case on referral from the Netherlands, and concluded that Dutch law is not compliant with EU law—i.e., the freedom of establishment—in denying tax consolidation (fiscal unity). Read more

Withholding tax

5 June 2014

The CJEU rendered its judgment in cases concerning withholding tax imposed on profit distributions made by Dutch companies to their parent companies resident on Curaçao.
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Treaties

Bilateral tax agreement

10 June 2014

New bilateral rules for the avoidance of double taxation between the Netherlands—including Dutch jurisdictions located in the Caribbean—and Curaçao were announced and presented on 10 June 2014 to the Dutch parliament for approval.
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Nigeria’s Federal High Court held that an advance ruling from the tax authority is not binding, so that the tax authority could subsequently reverse its position and determine that income derived by non-resident companies is subject to both corporate income tax and withholding tax in Nigeria.
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Legislation that would amend both the corporate income tax and individual income tax laws in Poland and that proposes rules on the taxation of controlled foreign corporations had its first reading in the Sejm in May 2014. Read more

One month after official publication, but not earlier than 1st January 2015

The RF Ministry of Finance has prepared a new version of the de-offshorization draft law to be submitted to the RF Government (the draft law). The draft law introduces into the RF Tax Code rules on the taxation of controlled foreign companies (CFC), tax residency criteria for companies, the taxation of income from the indirect transfer of ownership of Russian companies that own real estate (through the sale of shares in companies, more than 50 percent of whose assets directly or indirectly consist of real estate located in Russia), and also the concept of “beneficial owner” of income, which was not included in the previous version of the draft law.
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Representatives of the governments of South Africa and the United States signed on 9 June 2014 an intergovernmental agreement intended to improve international tax compliance and to implement the FATCA.
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Proposals for changes to the tax treatment of corporate financing activities have been considered by the Corporate Taxation Committee and were summarized in a 12 June 2014 final report that is now being circulated to agencies, organizations, and other stakeholders.
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In the last couple of months, most institutions affected by FATCA— financial institutions as well as non-financial companies—were still scrambling to become FATCA-compliant and considering steps for compliance with FATCA once it becomes effective on 1 July 2014.
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Treaties

Free trade agreement

1 July 2014

A free trade agreement between Switzerland and China will enter into force on 1 July 2014.
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The 2014 budget—presented in Uganda on 12 June 2014—reflects that the overall performance of the Uganda economy as measured by the real GDP at market prices is estimated to have grown by 5.7 percent for the financial year 2013/14 which is a 0.1 percent decrease compared to the revised growth of 5.8 percent that was recorded in the prior year. Read more

There were 146 financial institutions in Ukraine that self-registered on the IRS FATCA website, prior to 5 June 2014, as participating financial institutions, not covered by the intergovernmental agreement.
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The UK government published a regulatory update for implementing the FATCA intergovernmental agreement between the UK and the United States. These regulations are effective 30 June 2014 and replace the original 2013 regulations.
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Proposed legislation

Finance Bill

1-2 July 2014

The UK Finance Bill is scheduled to have its "report" stage in the House of Commons on 1 and 2 July. The government has published amendments on several Finance Bill clauses ahead of the bill’s report stage.
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Corporate transparency

16 April 2014

The department of Business Innovation & Skills on 16 April 2014 published a response paper on corporate transparency, which discusses proposals that would potentially affect limited liability partnerships. Read more

Taxation of authorized contractual schemes

June 2014

HM Revenue & Customs published draft guidance on the tax treatment of investments in tax-transparent “authorised contractual schemes”.
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